On December 19, 2025, Defense Pricing, Contracting, and Acquisition Policy (DPCAP) announced that DoD would release Department of War class deviations to the FAR and DFARS in two phases. Phase 1 — 31 class deviations to FAR and DFARS codified text — went effective at various points starting February 1, 2026. Phase 2 requires formal proposed FAR and DFARS rules issued for public notice and comment, planned for FY2026. Coverage from RedstoneGCI and DPCAP.
What changes in Phase 1
- 31 class deviations across FAR/DFARS
- DFARS text streamlined: removed, revised, or relocated procedures to DFARS PGI
- Cybersecurity provisions and clauses moved from FAR 52.204-xx to 52.240-xx
- Increased complexity around interpretation and definitions even as overall text shrinks
Why Phase 2 matters more
Class deviations are temporary — they let DoD test changes in real procurements without going through public comment. Phase 2 turns the most successful deviations into permanent rule changes. Public-comment windows are the moment industry can shape final language before it's locked in.
What to do
- Update FAR clause references in your contract templates — old 52.204-xx cyber clauses move to 52.240-xx
- Track DPCAP Phase 2 release calendar — file comments on the proposed rules that affect your business model
- Train BD/proposal teams to flag deviation clauses in agency-specific solicitations